Exhibit
EXHIBIT 1.02
STANLEY BLACK & DECKER, INC.
Conflict Minerals Report
For The Year Ended December 31, 2015
This report for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“the Rule”).
1. Overview
Stanley Black & Decker, Inc. ("the Company") is a diversified global provider of hand tools, power tools and related accessories, mechanical access solutions (i.e. automatic doors and commercial locking systems), electronic security and monitoring systems. The Company manufactures products for which tin, tantalum, tungsten and gold ("3TG minerals" or "conflict minerals") are necessary to the functionality or production of those products and which otherwise constitute products under the Rule.
In accordance with the Rule, the Company conducted a reasonable country of origin inquiry ("RCOI") that was reasonably designed to determine whether any of the 3TG minerals in the Company's products originated in the Democratic Republic of the Congo (the "DRC") or Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia ("adjoining countries"), or were from recycled or scrap sources. Based on the Company's RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products originated in the DRC or adjoining countries and may not have been from recycled or scrap sources. Accordingly, the Company exercised due diligence to determine the source and chain of custody of these 3TG minerals. The Company's due diligence was designed to materially conform to the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (2013) and the related Supplements for gold and for tin, tantalum and tungsten. A description of the Company's RCOI and due diligence measures is set forth in this report.
Product Description
The Company’s operations are classified into three operating segments: Tools & Storage, Security and Industrial.
Tools & Storage
The Tools & Storage segment is comprised of the Power Tools and Hand Tools & Storage businesses.
The Power Tools business includes professional products, consumer products and power tool accessories. Professional products include professional grade corded and cordless electric power tools and equipment including drills, impact wrenches and drivers, grinders, saws, routers and sanders, as well as pneumatic tools and fasteners including nail guns, nails, staplers and staples, concrete and masonry anchors. Consumer products include corded and cordless electric power tools sold primarily under the Black & Decker brand, lawn and garden products, including hedge trimmers, string trimmers, lawn mowers, edgers and related accessories, and home products, such as hand held vacuums, paint tools and cleaning appliances. Power tool accessories include drill bits, router bits, abrasives and saw blades.
The Hand Tools & Storage business sells measuring, leveling and layout tools, planes, hammers, demolition tools, knives, saws, chisels and industrial and automotive tools. Storage products include tool boxes, sawhorses, medical cabinets and engineered storage solution products.
Security
The Security segment is comprised of the Convergent Security Solutions ("CSS") and Mechanical Access Solutions ("MAS") businesses.
The CSS business designs, supplies and installs electronic security systems and provides electronic security services, including alarm monitoring, video surveillance, fire alarm monitoring, systems integration and system maintenance. The business also
includes healthcare solutions, which include asset tracking solutions, infant protection, pediatric protection, patient protection, wander management, fall management, and emergency call products.
The MAS business sells automatic doors, commercial hardware, locking mechanisms, electronic keyless entry systems, keying systems, tubular and mortise door locksets.
Industrial
The Industrial segment is comprised of the Engineered Fastening and Infrastructure businesses.
The Engineered Fastening business primarily sells engineered fastening products and systems designed for specific applications. The product lines include stud welding systems, blind rivets and tools, blind inserts and tools, drawn arc weld studs, engineered plastic and mechanical fasteners, self-piercing riveting systems, precision nut running systems, micro fasteners, and high-strength structural fasteners.
The Infrastructure business consists of the Oil & Gas and Hydraulics businesses. The Oil & Gas business sells and rents custom pipe handling, joint welding and coating equipment used in the construction of large and small diameter pipelines, and provides pipeline inspection services. The Hydraulics business sells hydraulic tools and accessories.
This report primarily covers the businesses and their products described above except for those which were determined to be out-of-scope of the Rule, primarily CSS and Oil & Gas.
Supply Chain
The Company both manufactures and contracts to manufacture its products described above, as well as components and raw materials for those products. Some of those products may be manufactured using 3TG minerals which are procured globally and from multiple suppliers who are several tiers away from the origin of and smelters of their raw materials. As such, the Company does not typically have a direct relationship with smelters and refiners of 3TG minerals. Additionally, the Company’s size, complexity of its products, and the depth, breadth and constant evolution of its supply chain, make it difficult to identify sub-tier suppliers from its direct suppliers, and therefore, the Company is reliant upon its direct suppliers to provide information on the origin of 3TG minerals contained in components and materials purchased. The Company’s suppliers are similarly reliant upon information provided by their suppliers and therefore face similar challenges to obtaining origin information. Additionally, many of the Company’s suppliers and its suppliers’ suppliers are foreign and not directly subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“the Dodd-Frank Act”).
Conflict Minerals Policy
The Company adopted the following Conflict Minerals Policy:
Stanley Black & Decker is committed to conducting business in an ethical, law abiding manner. This includes our commitment to not only comply with all applicable laws and regulations but also to operate our business on a foundation of integrity, trust and respect throughout our supply chain. Along with governmental and non-governmental organizations, civil society and affected third parties, we are concerned about the potential human rights issues, such as forced labor, inhumane or cruel treatment, and child labor, associated with the mining of Conflict Minerals (defined as tin, tungsten, tantalum and gold) which are occurring in the Democratic Republic of Congo ("DRC") and adjoining countries (“DRC region”).
Stanley Black & Decker is cognizant of our obligations under Section 1502 of the Dodd-Frank Act and is working with our suppliers to meet the due diligence and reporting requirements of Section 1502. As part of this process, we are helping our suppliers understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products they sell us. If, based on our due diligence, we determine there is a reasonable risk that Conflict Minerals in our products may be directly or indirectly linked to the financing of conflict in the DRC region, we will determine an appropriate course of action based on the facts and circumstances relating to the affected products. Such action may include, but is not limited to, the suspension or termination of our relationship with particular suppliers.
Determining whether all products sold by Stanley Black & Decker are Conflict Free is a time consuming and difficult process. We manufacture and distribute thousands of products, many of which contain, or may contain, the minerals that have been defined as Conflict Minerals. We source the raw materials and component parts for the products we manufacture, as well as finished products, from thousands of other companies around the world. Stanley Black & Decker is and has been working with our suppliers to educate them regarding Stanley Black & Decker’s disclosure obligations under the Dodd-Frank Act and
concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they supply to us.
Stanley Black & Decker has the following expectations of its suppliers:
| |
• | suppliers should identify any products sold to Stanley Black & Decker that contain any Conflict Minerals which are not DRC Conflict Free; |
| |
• | suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to Stanley Black & Decker; and |
| |
• | Stanley Black & Decker suppliers should source Conflict Minerals only from sources that are DRC conflict free. |
In doing so, suppliers will be expected to:
| |
• | implement and communicate to their personnel and suppliers policies that are consistent with this policy, and require their direct and indirect suppliers to do the same; |
| |
• | put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable; |
| |
• | use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require their direct and indirect suppliers to do the same; |
| |
• | advise Stanley Black & Decker of any determination that the supplier either has concluded or has a reasonable basis to believe the products it currently sells or has sold to Stanley Black & Decker are not DRC Conflict Free; |
| |
• | maintain reviewable business records supporting the source of Conflict Minerals; and |
| |
• | from time to time, at Stanley Black & Decker's request, provide Stanley Black & Decker with information concerning the origin of Conflict Minerals included in products sold to Stanley Black & Decker, which Stanley Black & Decker shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of a confidentiality agreement that do not specifically reference this paragraph. |
Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.
Consequences of supplier noncompliance
Stanley Black & Decker evaluates its relationships with its suppliers on an ongoing basis. Stanley Black & Decker reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this policy. Stanley Black & Decker also reserves the right to request additional documentation from suppliers regarding the origin of any Conflict Minerals included in any products sold to Stanley Black & Decker.
Suppliers who do not reasonably comply with this policy shall be reviewed by Stanley Black & Decker’s Global Supply Management ("GSM") organization for future business.
In the event Stanley Black & Decker determines that the supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Stanley Black & Decker reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier. Nothing in this policy is intended to in any way grant any additional rights or expectations to any Stanley Black & Decker supplier or in any way modify or otherwise limit in any way any of Stanley Black & Decker's contractual or legal rights.
Grievance mechanism and reporting
Our employees, suppliers and other parties can report concerns and alleged violations of this policy as follows:
| |
(i) | Write us at Stanley Black & Decker: Stanley Black & Decker, Inc., Attn: Conflict Minerals Steering Committee, 1000 Stanley Drive, New Britain, CT 06053 |
| |
(ii) | e-mail us at: [conflictminerals@sbdinc.com] |
| |
(iii) | Call us at: 877-795-2358 |
Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law. We will not take any retaliatory action against our employees, suppliers or other parties who make a report in good faith. Our suppliers are encouraged to contact [conflictminerals@sbdinc.com] if they wish to seek guidance on the application of this policy.
Conclusion
Stanley Black & Decker fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.
This policy is publicly available at www.stanleyblackanddecker.com/about/sustainability.
RCOI
Prior to conducting the Company's RCOI, the Company performed a risk-based assessment of its products for components and/or raw materials which were most likely to contain 3TG minerals. The Company required direct suppliers of those components and/or raw materials to complete a supply chain survey using the Conflict-Free Sourcing Initiative's ("CFSI") Conflict Minerals Reporting Template to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.
Suppliers who were delinquent in responding to the Company's survey by the specified date, were contacted, at a minimum, via two non-system generated emails and a phone call or read receipt email, in an effort to obtain responses.
Smelters and refiners identified in the survey responses were aggregated and then validated against the CFSI's Standard Smelter List, and once validated, against the CFSI's Conflict Free Smelter Program ("CFSP") to determine compliance status. CFSP compliant smelters and refiners were than validated against the CFSI's RCOI Data Document to determine country of origin information for the minerals being processed by the smelters and refiners.
Based on the suppliers' responses to the RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products may have originated in the DRC or adjoining countries and may not have been from recycled or scrap sources.
2. Due Diligence
2.1 Design of Due Diligence
The Company's due diligence measures are designed to materially conform with the Organisation for Economic Co-operation and Development ("the OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (2013) and the related Supplements for gold and for tin, tantalum and tungsten (collectively "the OECD Guidance").
OECD Step 1: Establish Strong Company Management Systems
Company Policy
The Company has a Conflict Mineral Policy which is posted on its website at www.stanleyblackanddecker.com/about/sustainability.
Internal Team
The Company has a Steering Committee sponsored by the Company’s Chief Financial Officer, as well as a Working Group. Members of the Steering Committee and Working Group are subject matter experts from relevant functions such as Global Supply Management, Sustainability, Finance and Legal. The Steering Committee is responsible for oversight of the Company’s conflict minerals compliance strategy and due diligence process, monitoring the due diligence progress, ensuring communication of critical information reaches employees and suppliers, and ensuring the timely and accurate filing of this report. The Working Group is charged with implementation of the Company's policy, conducting due diligence, communications to suppliers and others, and reporting its progress to the Steering Committee on a regular basis.
System of Controls and Transparency Over the Supply Chain
The Company utilizes the Conflict-Free Sourcing Initiative's (“CFSI”) Conflict Minerals Reporting Template (“the CMRT”), a supply chain survey designed to gather information from a company's suppliers to determine whether any of the components and/or raw materials provided to the company originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.
Supplier Engagement
The Company's Conflict Mineral Policy is posted on its supplier portal for all suppliers to access. Additionally, the Company's supplier Master Purchase Agreements include a Conflict Minerals provision which requires its suppliers to provide information necessary to allow the Company and its customers to comply with the provisions of the Dodd-Frank Act and explicitly gives the Company the rights to audit the supply chain and terminate arrangements with suppliers who are unwilling or unable to comply. As supplier Master Purchase Agreements are generally in force for one to three years, it will take a number of years to ensure that all Master Purchase Agreements contain this provision. While the Company cannot unilaterally impose new contract terms, including those that would compel its suppliers to support the Company's conflict minerals due diligence efforts, existing Master Purchase Agreements contain a compliance with laws clause which provides for the Company’s suppliers to abide by directives from the Company to be in compliance with applicable laws.
Grievance Mechanism
The Company has an established grievance mechanism for reporting violations of the Company’s policies.
Maintain Records
The Company maintains Conflict Mineral related information in accordance with its record retention policy.
OECD Step 2: Identify and Assess Risk in the Supply Chain
The Company performs a risk-based assessment of its products for components and/or raw materials which are most likely to contain 3TG minerals and surveys suppliers of those components and/or raw materials using the CMRT to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, identify smelters and refiners in the Company's supply chain. Identified smelters and refiners are aggregated and validated against the CFSI's Standard Smelter List, and once validated, against the CFSI's Conflict Free Smelter Program ("CFSP") to determine compliance status.
The Company reviews responses to the survey for red flags in order to identify areas of potential risk such as incomplete responses, insufficient due diligence or potentially higher risk sourcing based upon criteria internally defined.
OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks
Results of the supply chain assessment are reported to the Steering Committee which is responsible for monitoring any actual or potential risks identified in the supply chain and reporting findings to the Company's Chief Financial Officer.
The Company has a risk mitigation plan to manage its non-compliant suppliers towards conformity with the Company's Conflict Mineral policy. GSM is responsible for taking appropriate actions up to and including suspension or termination of the Company's relationship with non-compliant suppliers.
The Company supports the CFSI's Conflict Free Smelter Program ("CFSP") which audits smelters' and refiners' due diligence activities. The data on which the Company relies for certain statements in this report is obtained through the Company's membership (member "SBDI") in the CFSI, using the reasonable country of origin inquiry report for the Company, or based upon the information publicly available on the CFSI's website.
The Company's new product introduction process includes a step to ensure information on the presence of 3TG minerals in new products is provided to the Working Group for integration into the Company's due diligence procedures. The Company has also revised its new product specifications to ensure that the use of 3TG is limited solely to the product's functionality.
OECD Step 4: Carry Out Independent Third Party Audit of Smelter/Refiner's Due Diligence Practices
The Company supports the CFSP's efforts to audit the due diligence practices of the smelters and refiners, through its active membership in the CFSI. The Company utilizes information on the CFSI's website (www.conflictfreesmelter.org) to determine which smelters and refiners are CFSP compliant.
OECD Step 5: Report Annually on Supply Chain Due Diligence
This report is the Company’s annual report on its due diligence, is filed along with Form SD with the Securities and Exchange Commission, and is publicly available on the Company’s website.
2.2 Due Diligence Performed
The Company performed the following due diligence for the reporting period:
| |
• | Identified suppliers of components and/or raw materials which were most likely to contain 3TG minerals and surveyed those suppliers using the latest published CMRT. Those suppliers were engaged through direct electronic communication from the Vice President of GSM, followed by an electronic communication through the Company’s supplier relationship management tool. |
| |
• | Identified suppliers providing 3TG minerals from the DRC or adjoining countries and compiled an aggregate list of smelters and refiners identified by those suppliers. |
| |
• | Compared those identified smelters and refiners against those smelters and refiners as validated by the CFSI. |
| |
• | Compared those validated smelters and refiners against those identified by the CFSI's CFSP as CFSP compliant or CFSP active and for those that are CFSP compliant, against the CFSI's RCOI Data Document to determine country of origin for the 3TG minerals processed by those smelters and refiners. |
| |
• | Provided non-responsive suppliers and red flag suppliers to GSM for follow-up. |
| |
• | Reported status of due diligence progress, including identification of red flag suppliers, to the Company's Steering Committee and to the Company's Chief Financial Officer. |
| |
• | Supported the CFSP through maintenance of an active membership in the CFSI. |
3. Due Diligence Results
The Company received responses from 45% of its suppliers surveyed. The Company’s suppliers are generally several tiers away from the origin of and smelters of their raw materials, and are therefore faced with similar challenges in performing their due diligence. In some instances, the information provided by the Company's suppliers is incomplete or not verified, and the Company is therefore unable to verify with certainty the source and chain of custody of all the 3TG minerals in the Company's supply chain.
The Company identified 321 smelters and refiners, as reported by the Company's suppliers, as potentially having processed the 3TG minerals contained in the Company's products for the reporting period. Some of the Company's suppliers responded at a company-level rather than product-level; therefore, there may be more smelters and refiners included in the Company's results than those that actually processed the 3TG minerals contained in the Company's products. The Company has only included in its results those smelters and refiners that have been validated as smelters and refiners appearing on the CFSI Standard Smelter List as of November 16, 2015. Other processing facilities were reported in the Company's supply chain; however, are not included in its results, as they have not yet been validated by the CFSI. The identified smelters and refiners are further broken out as follows:
|
| | | | | |
Smelters and Refiners | Gold | Tantalum | Tin | Tungsten | Total |
Number of CFSI validated | 131 | 49 | 91 | 50 | 321 |
Number of CFSP compliant* | 95 | 47 | 76 | 46 | 264 |
% CFSP compliant | 73% | 96% | 84% | 92% | 82% |
*Includes 36 smelters and refiners that are active in the CFSP as of May 23, 2015.
The following tables list smelters and refiners identified by the Company's suppliers' survey responses.
Table 1. CFSP Compliant Smelters and Refiners
The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have been validated as compliant according to the CFSP as of May 23, 2016.
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Gold | AGR Matthey | CID002030 | Australia |
Gold | Aida Chemical Industries Co., Ltd. | CID000019 | Japan |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | Germany |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 | Brazil |
Gold | Argor-Heraeus S.A. | CID000077 | Switzerland |
Gold | Asahi Pretec Corporation | CID000082 | Japan |
Gold | Asahi Refining Canada Limited | CID000924 | Canada |
Gold | Asahi Refining USA Inc. | CID000920 | United States |
Gold | Asaka Riken Co., Ltd. | CID000090 | Japan |
Gold | Aurubis AG | CID000113 | Germany |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | Philippines |
Gold | Boliden AB | CID000157 | Sweden |
Gold | C. Hafner GmbH + Co. KG | CID000176 | Germany |
Gold | CCR Refinery – Glencore Canada Corporation | CID000185 | Canada |
Gold | Chimet S.p.A. | CID000233 | Italy |
Gold | DODUCO GmbH | CID000362 | Germany |
Gold | Dowa | CID000401 | Japan |
Gold | Eco-System Recycling Co., Ltd. | CID000425 | Japan |
Gold | Elemetal Refining, LLC | CID001322 | United States |
Gold | Emirates Gold DMCC | CID002561 | United Arab Emirates |
Gold | Heimerle + Meule GmbH | CID000694 | Germany |
Gold | Heraeus Ltd. Hong Kong | CID000707 | China |
Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 | Germany |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | China |
Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | Japan |
Gold | Istanbul Gold Refinery | CID000814 | Turkey |
Gold | Japan Mint | CID000823 | Japan |
Gold | Jiangxi Copper Co., Ltd. | CID000855 | China |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | Russian Federation |
Gold | JSC Uralelectromed | CID000929 | Russian Federation |
Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | Japan |
Gold | Kazzinc | CID000957 | Kazakhstan |
Gold | Kennecott Utah Copper LLC | CID000969 | United States |
Gold | Kojima Chemicals Co., Ltd | CID000981 | Japan |
Gold | LS-NIKKO Copper Inc. | CID001078 | Korea |
Gold | Matsuda Sangyo Co., Ltd. | CID001119 | Japan |
Gold | Metalor Technologies (Hong Kong) Ltd | CID001149 | China |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | Singapore |
Gold | Metalor Technologies S.A. | CID001153 | Switzerland |
Gold | Metalor USA Refining Corporation | CID001157 | United States |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 | Mexico |
Gold | Mitsubishi Materials Corporation | CID001188 | Japan |
Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | Japan |
Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | India |
Gold | Moscow Special Alloys Processing Plant | CID001204 | Russian Federation |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 | Turkey |
Gold | Nihon Material Co., Ltd. | CID001259 | Japan |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | Austria |
Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | Japan |
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | Russian Federation |
Gold | OJSC Novosibirsk Refinery | CID000493 | Russian Federation |
Gold | PAMP S.A. | CID001352 | Switzerland |
Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | Russian Federation |
Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | Indonesia |
Gold | PX Précinox S.A. | CID001498 | Switzerland |
Gold | Rand Refinery (Pty) Ltd. | CID001512 | South Africa |
Gold | Republic Metals Corporation | CID002510 | United States |
Gold | Royal Canadian Mint | CID001534 | Canada |
Gold | Schone Edelmetaal B.V. | CID001573 | Netherlands |
Gold | SEMPSA Joyería Platería S.A. | CID001585 | Spain |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | China |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | China |
Gold | Singway Technology Co., Ltd. | CID002516 | Taiwan |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | Russian Federation |
Gold | Solar Applied Materials Technology Corp. | CID001761 | Taiwan |
Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | Japan |
Gold | T.C.A S.p.A | CID002580 | Italy |
Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | Japan |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | China |
Gold | Tokuriki Honten Co., Ltd. | CID001938 | Japan |
Gold | Umicore Brasil Ltda | CID001977 | Brazil |
Gold | Umicore Precious Metals Thailand | CID002314 | Thailand |
Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | Belgium |
Gold | United Precious Metal Refining, Inc. | CID001993 | United States |
Gold | Valcambi S.A. | CID002003 | Switzerland |
Gold | Williams Advanced Materials | CID001113 | United States |
Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 | Japan |
Gold | Yokohama Metal Co., Ltd. | CID002129 | Japan |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | China |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CID002243 | China |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | China |
Tantalum | Conghua Tantalum and Niobium Smeltry | CID000291 | China |
Tantalum | D Block Metals, LLC | CID002504 | United States |
Tantalum | Duoluoshan | CID000410 | China |
Tantalum | Exotech Inc. | CID000456 | United States |
Tantalum | F&X Electro-Materials Ltd. | CID000460 | China |
Tantalum | FIR Metals & Resource Ltd. | CID002505 | China |
Tantalum | Global Advanced Metals Aizu | CID002558 | Japan |
Tantalum | Global Advanced Metals Boyertown | CID002557 | United States |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | China |
Tantalum | H.C. Starck Co., Ltd. | CID002544 | Thailand |
Tantalum | H.C. Starck GmbH Goslar | CID002545 | Germany |
Tantalum | H.C. Starck GmbH Laufenburg | CID002546 | Germany |
Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 | Germany |
Tantalum | H.C. Starck Inc. | CID002548 | United States |
Tantalum | H.C. Starck Ltd. | CID002549 | Japan |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | CID002550 | Germany |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | China |
Tantalum | Hi-Temp Specialty Metals, Inc. | CID000731 | United States |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | China |
Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | China |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | China |
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | China |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | China |
Tantalum | KEMET Blue Metals | CID002539 | Mexico |
Tantalum | Kemet Blue Powder | CID002568 | United States |
Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 | China |
Tantalum | LSM Brasil S.A. | CID001076 | Brazil |
Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | India |
Tantalum | Mineração Taboca S.A. | CID001175 | Brazil |
Tantalum | Mitsui Mining & Smelting | CID001192 | Japan |
Tantalum | Molycorp Silmet A.S. | CID001200 | Estonia |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | China |
Tantalum | Plansee SE Liezen | CID002540 | Austria |
Tantalum | Plansee SE Reutte | CID002556 | Austria |
Tantalum | QuantumClean | CID001508 | United States |
Tantalum | Resind Indústria e Comércio Ltda. | CID002707 | Brazil |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 | China |
Tantalum | Solikamsk Magnesium Works OAO | CID001769 | Russian Federation |
Tantalum | Taki Chemicals | CID001869 | Japan |
Tantalum | Telex Metals | CID001891 | United States |
Tantalum | Tranzact, Inc. | CID002571 | United States |
Tantalum | Ulba Metallurgical Plant JSC | CID001969 | Kazakhstan |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | China |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 | China |
Tantalum | Zhuzhou Cemented Carbide | CID002232 | China |
Tin | Alpha | CID000292 | United States |
Tin | China Tin Group Co., Ltd. | CID001070 | China |
Tin | Cooper Santa | CID000295 | Brazil |
Tin | CV Ayi Jaya | CID002570 | Indonesia |
Tin | CV Gita Pesona | CID000306 | Indonesia |
Tin | CV Serumpun Sebalai | CID000313 | Indonesia |
Tin | CV United Smelting | CID000315 | Indonesia |
Tin | CV Venus Inti Perkasa | CID002455 | Indonesia |
Tin | Dowa | CID000402 | Japan |
Tin | Elmet S.L.U. | CID002774 | Spain |
Tin | EM Vinto | CID000438 | Bolivia |
Tin | Fenix Metals | CID000468 | Poland |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | China |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 | China |
Tin | Magnu's Minerais Metais e Ligas LTDA | CID002468 | Brazil |
Tin | Malaysia Smelting Corporation (MSC) | CID001105 | Malaysia |
Tin | Melt Metais e Ligas S/A | CID002500 | Brazil |
Tin | Metallic Resources, Inc. | CID001142 | United States |
Tin | Metallo-Chimique N.V. | CID002773 | Belgium |
Tin | Mineração Taboca S.A. | CID001173 | Brazil |
Tin | Minsur | CID001182 | Peru |
Tin | Mitsubishi Materials Corporation | CID001191 | Japan |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | Thailand |
Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | Philippines |
Tin | OMSA | CID001337 | Bolivia |
Tin | PT Aries Kencana Sejahtera | CID000309 | Indonesia |
Tin | PT Artha Cipta Langgeng | CID001399 | Indonesia |
Tin | PT ATD Makmur Mandiri Jaya | CID002503 | Indonesia |
Tin | PT Babel Inti Perkasa | CID001402 | Indonesia |
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Tin | PT Bangka Prima Tin | CID002776 | Indonesia |
Tin | PT Bangka Tin Industry | CID001419 | Indonesia |
Tin | PT Belitung Industri Sejahtera | CID001421 | Indonesia |
Tin | PT BilliTin Makmur Lestari | CID001424 | Indonesia |
Tin | PT Bukit Timah | CID001428 | Indonesia |
Tin | PT Cipta Persada Mulia | CID002696 | Indonesia |
Tin | PT DS Jaya Abadi | CID001434 | Indonesia |
Tin | PT Eunindo Usaha Mandiri | CID001438 | Indonesia |
Tin | PT Inti Stania Prima | CID002530 | Indonesia |
Tin | PT Justindo | CID000307 | Indonesia |
Tin | PT Mitra Stania Prima | CID001453 | Indonesia |
Tin | PT Panca Mega Persada | CID001457 | Indonesia |
Tin | PT Prima Timah Utama | CID001458 | Indonesia |
Tin | PT Refined Bangka Tin | CID001460 | Indonesia |
Tin | PT Sariwiguna Binasentosa | CID001463 | Indonesia |
Tin | PT Stanindo Inti Perkasa | CID001468 | Indonesia |
Tin | PT Sukses Inti Makmur | CID002816 | Indonesia |
Tin | PT Sumber Jaya Indah | CID001471 | Indonesia |
Tin | PT Timah (Persero) Tbk Kundur | CID001477 | Indonesia |
Tin | PT Timah (Persero) Tbk Mentok | CID001482 | Indonesia |
Tin | PT Tinindo Inter Nusa | CID001490 | Indonesia |
Tin | PT Tommy Utama | CID001493 | Indonesia |
Tin | PT Wahana Perkit Jaya | CID002479 | Indonesia |
Tin | Resind Indústria e Comércio Ltda. | CID002706 | Brazil |
Tin | Rui Da Hung | CID001539 | Taiwan |
Tin | Soft Metais, Ltda. | CID001758 | Brazil |
Tin | Thaisarco | CID001898 | Thailand |
Tin | VQB Mineral and Trading Group JSC | CID002015 | Vietnam |
Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 | Brazil |
Tin | Yunnan Tin Company Limited | CID002180 | China |
Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 | Japan |
Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | Vietnam |
Tungsten | ATI Tungsten Materials | CID000105 | United States |
Tungsten | Chaozhou Xianglu Tungsten Industry Co Ltd | CID000218 | China |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | China |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | China |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CID002518 | China |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CID000345 | China |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 | China |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | China |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | China |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CID000868 | China |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | China |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CID002536 | China |
Tungsten | Global Tungsten & Powders Corp. | CID000568 | United States |
Tungsten | H.C. Starck GmbH | CID002541 | Germany |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 | Germany |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | China |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 | China |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | China |
Tungsten | Hydrometallurg, JSC | CID002649 | Russian Federation |
Tungsten | Japan New Metals Co., Ltd. | CID000825 | Japan |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | China |
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | China |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | China |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | China |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 | China |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | China |
Tungsten | Kennametal Fallon | CID000966 | United States |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | China |
Tungsten | Niagara Refining LLC | CID002589 | United States |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 | Vietnam |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | Philippines |
Tungsten | Pobedit, JSC | CID002532 | Russian Federation |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CID002815 | China |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | Vietnam |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 | Vietnam |
Tungsten | Wolfram Bergbau und Hütten AG | CID002044 | Austria |
Tungsten | Woltech Korea Co., Ltd. | CID002843 | Korea |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | China |
Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | China |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 | China |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 | China |
The Company requested both country of origin information and mine or location of origin information from its suppliers for purposes of determining the source and chain of custody of the 3TG minerals in the Company's supply chain. The Company relied on country of origin information provided by its suppliers (if known), as well as by the CFSI's CFSP and RCOI Data Document. Some of the Company's suppliers provided mine or location of origin information, but many were unable to obtain such information for their 3TG minerals.
Sixteen of the CFSP compliant gold smelters and refiners included in Table 1 have disclosed mineral sources as originating from recycled and scrap sources and/or from the following countries: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Côte d'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States of America, Vietnam and Zimbabwe. The remaining gold smelters and refiners' mineral sources is not available as of May 3, 2016.
CFSP compliant tantalum, tin and tungsten smelters and refiners included in Table 1 have disclosed mineral sources as originating from Kenya, Mozambique, South Africa, and the DRC and adjoining countries, in addition to the countries listed above and recycled and scrap sources.
Based on this country of origin information, the Company has reason to believe that some of the 3TG minerals used in the Company's products may have originated in the DRC or adjoining countries.
Table 2. CFSP Participating Smelters and Refiners
The following table lists smelters and refiners identified by the Company's suppliers ' survey responses that have agreed to participate in the CFSP but have not yet completed the program as of May 23, 2016.
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Gold | Advanced Chemical Company | CID000015 | United States |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | Uzbekistan |
Gold | Cendres + Métaux S.A. | CID000189 | Switzerland |
Gold | Daejin Indus Co., Ltd. | CID000328 | Korea |
Gold | DSC (Do Sung Corporation) | CID000359 | Korea |
Gold | Faggi Enrico S.p.A. | CID002355 | Italy |
Gold | Geib Refining Corporation | CID002459 | United States |
Gold | KGHM Polska Miedź Spółka Akcyjna | CID002511 | Poland |
Gold | Korea Zinc Co., Ltd. | CID002605 | Korea |
Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | China |
Gold | Navoi Mining and Metallurgical Combinat | CID001236 | Uzbekistan |
Gold | Samduck Precious Metals | CID001555 | Korea |
Gold | SAXONIA Edelmetalle GmbH | CID002777 | Germany |
Gold | Torecom | CID001955 | Korea |
Gold | WIELAND Edelmetalle GmbH | CID002778 | Germany |
Tantalum | E.S.R. Electronics | CID002590 | United States |
Tin | An Thai Minerals Company Limited | CID002825 | Vietnam |
Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | Vietnam |
Tin | Chenzhou Yun Xiang mining limited liability company | CID000228 | China |
Tin | CV Dua Sekawan | CID002592 | Indonesia |
Tin | CV Tiga Sekawan | CID002593 | Indonesia |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | Vietnam |
Tin | Gejiu Fengming Metalurgy Chemical Plant | CID002848 | China |
Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | China |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | China |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 | China |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | China |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | Vietnam |
Tin | Phoenix Metal Ltd. | CID002507 | Rwanda |
Tin | PT Karimun Mining | CID001448 | Indonesia |
Tin | PT Kijang Jaya Mandiri | CID002829 | Indonesia |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | Vietnam |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | China |
Tungsten | ACL Metais Eireli | CID002833 | Brazil |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 | China |
Tungsten | Moliren Ltd | CID002845 | Russian Federation |
Mineral sources for CFSP participating smelters and refiners are not available.
Table 3. Smelters and Refiners with No Known CFSP Participation
The following table lists smelters and refiners identified by the Company's suppliers ' survey responses that have not been validated as compliant according to the CFSP as of May 23, 2016.
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Gold | Aktyubinsk Copper Company TOO | CID000028 | Kazakhstan |
Gold | Al Etihad Gold Refinery DMCC | CID002560 | United Arab Emirates |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | Turkey |
Gold | Bauer Walser AG | CID000141 | Germany |
|
| | | |
Mineral | Smelter or Refiner Facility Name | CFSI Smelter Identification | Facility Location |
Gold | Caridad | CID000180 | Mexico |
Gold | Chugai Mining | CID000264 | Japan |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | China |
Gold | Fidelity Printers and Refiners Ltd. | CID002515 | Zimbabwe |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CID000522 | China |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | China |
Gold | Guangdong Jinding Gold Limited | CID002312 | China |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | China |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | China |
Gold | Hunan Central South Gold Smelting Company Limited | CID000767 | China |
Gold | Hwasung CJ Co., Ltd. | CID000778 | Korea |
Gold | Kaloti Precious Metals | CID002563 | United Arab Emirates |
Gold | Kazakhmys Smelting LLC | CID000956 | Kazakhstan |
Gold | Korea Metal Co., Ltd. | CID000988 | Korea |
Gold | Kyrgyzaltyn JSC | CID001029 | Kyrgyzstan |
Gold | L'azurde Company For Jewelry | CID001032 | Saudi Arabia |
Gold | Lingbao Gold Co., Ltd. | CID001056 | China |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | China |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | China |
Gold | Metahub Industries Sdn. Bhd. | CID002821 | Malaysia |
Gold | Morris and Watson | CID002282 | New Zealand |
Gold | OJSC Kolyma Refinery | CID001328 | Russian Federation |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | China |
Gold | SAAMP | CID002761 | France |
Gold | Sabin Metal Corp. | CID001546 | United States |
Gold | SAMWON Metals Corp. | CID001562 | Korea |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | China |
Gold | So Accurate Group, Inc. | CID001754 | United States |
Gold | Sudan Gold Refinery | CID002567 | Sudan |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | China |
Gold | Tony Goetz NV | CID002587 | Belgium |
Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | China |
Tantalum | Avon Specialty Metals Ltd | CID002705 | United Kingdom |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CID002501 | China |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 | China |
Tin | Estanho de Rondônia S.A. | CID000448 | Brazil |
Tin | Feinhütte Halsbrücke GmbH | CID000466 | Germany |
Tin | Gejiu Zi-Li | CID000555 | China |
Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 | China |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CID001063 | China |
Tin | Metahub Industries Sdn. Bhd. | CID001136 | Malaysia |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CID001231 | China |
Tin | PT Alam Lestari Kencana | CID001393 | Indonesia |
Tin | PT Bangka Kudai Tin | CID001409 | Indonesia |
Tin | PT Bangka Timah Utama Sejahtera | CID001416 | Indonesia |
Tin | PT Fang Di MulTindo | CID001442 | Indonesia |
Tin | PT Pelat Timah Nusantara Tbk | CID001486 | Indonesia |
Tin | PT Seirama Tin Investment | CID001466 | Indonesia |
Tin | PT Tirus Putra Mandiri | CID002478 | Indonesia |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CID002531 | China |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CID002578 | China |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | China |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | CID002538 | Vietnam |
4. Steps to be Taken to Mitigate Risk
The Company intends to take the following steps to mitigate the risk that 3TG minerals contained in the Company’s products could benefit armed groups in the DRC or adjoining countries:
| |
• | Continue to encourage the Company's suppliers to improve response rates and the content of responses, including names, country of origin and mine or location of origin. Continue to use and encourage the Company's suppliers to use the Conflict Minerals Resources Center and other publicly available tools from the CFSI. Engage suppliers to request their smelters and refiners participate in the CFSP or other independent third party audit programs. |
| |
• | Continue to provide non-validated processing facilities to the CFSI for validation and potential participation in the CFSP. |
| |
• | Continue to support the CFSI's efforts to support the responsible sourcing of minerals. |
| |
• | Encourage the Company's suppliers to consider alternative sources for the 3TG minerals. |
| |
• | Continue to integrate Conflict Minerals contractual language in the Company’s new or renewed supplier contracts. |
| |
• | Determine an appropriate course of action which may include, but is not limited to, the suspension or termination of the Company's relationship with a non-compliant supplier. |
| |
• | Engage with a compliance risk solution supplier to facilitate the conflict mineral survey process. |
The Company recognizes that due diligence is a dynamic process and requires on-going risk monitoring. After implementing these risk mitigation strategies, the Company will reassess the effectiveness of its risk management plan, and may adapt further strategies or refine existing strategies to ensure effective risk mitigation. Furthermore, future acquisitions will be integrated into the Company's due diligence processes.
